The party responsible for the Integrity Line is Linde AG, Klosterhofstraße 1, 80331 Munich.

The Integrity Line reporting channels

Mail

Email

Telefax

Internet portal

are operated by Linde AG.

The Integrity Line telephone hotline is operated on behalf of Linde by a third party service provider. Currently this is Expolink Europe Ltd., 6 Greenways Business Park, Bellinger Close, Chippenham, SN15 1BN. A suitable data processing agreement in accordance with the requirements of EU data privacy laws is in place with the service provider.

The service provider takes the call, accumulates the information and forwards this information to Linde AG via an encrypted email connection. Further handling of the submitted information is done by Linde AG.

When using the Integrity Line for reporting relevant misbehavior, the following personal information is typically collected (to the extent you provide it in your report):

your name, your company, your contact details and whether you are a Linde employee or not;

the name and other personal information of the reported person stated in your report in as far as you make such information available;

a description of the reported misbehavior in question as well as a description of the facts and circumstances surrounding the incident and whether anonymity of the reporting person is desired or not.

You should only report relevant information which is necessary for investigating and sanctioning a relevant misbehavior which you assume – to the best of your knowledge – to be correct and true. Giving false or misleading information in bad faith may have negative consequences for you. The intentional dissemination of false information may lead to disciplinary sanctions and criminal prosecution in many countries.

Linde will use personal information contained in a report solely and exclusively for the specified purposes for which they were originally collected via the Integrity Line, i.e. for the investigation and mitigation of the alleged misbehavior and for potentially necessary further legal steps and legal proceedings (if any).

Linde will not use personal information contained in a report for any other purpose whatsoever, except where the concerned person has given his / her consent.

The handling of personal information contained in reports is based on the legitimate business interest of the Linde Group to rely on good corporate governance principles and to ensure an adequate functioning of the organization. It is recognized that an organization must be able to put in place appropriate procedures to enable stakeholders to report irregularities, to conduct an independent investigation of such allegations and to take appropriate follow-up action.

All personal information stated in your report is stored in a case management system software operated by the service provider Business Keeper AG in its data center in Germany. Only two (2) dedicated employees of Linde AG – the so called Integrity Line Facilitator (ILF) - as well as the four (4) members of the Linde Integrity Committee (IC) have access to the reports and all personal information held within the Linde Integrity Line.

Depending on the content of the report, the report may be shared with the concerned local Linde entity, with courts or with the police and/or other investigative authorities or governmental agencies (to the extent required or permitted by applicable law).

To this end, the recipients to which personal information may be transferred in the course of the investigation might be located outside the EU/EEA where the level of data protection is not comparable with the protection level afforded in the EU/EEA. Within the Linde Group, an adequate protection level is ensured globally by internal guidelines and agreements. Transfer of personal information to external recipients outside the EU/EEA will only take place after adequate safeguards to protect the information have been taken (e.g. EU Standard Contractual Clauses).

Further details can be found under the bullet point “What happens to my report?” at the entry page of the Integrity Line internet portal.

The Integrity Line and the information contained therein is protected against loss, abuse, unauthorized access, distribution, modification and destruction by adequate and state of the art technical and organizational measures. The data is kept on protected servers in a highly secured data center operated by the Business Keeper AG in Germany on behalf of Linde AG. All data is encrypted, password-protected and stored at a secure location. Access to the stored information is only granted to a narrow circle of authorized persons which are all trained in data privacy and personally bound by explicit confidentiality undertakings.

The reported person will be duly informed about the allegations about him received through the Integrity Line. He / she will have an opportunity to comment on the facts and circumstances described in the report.

In specific cases, where such information would put the investigation at risk, the information of the reported person may be delayed as long as such risk exists.

The reported person has a right to access the information stored about him / her in the Integrity Line. However, he / she has no right to be informed about the identity of the reporting person, unless the reporting person has made false allegations in bad faith.

The reporting person and the reported person as well as other persons mentioned in the report have a right to be informed about the information collected about them, to access their personal information, to have unlawfully collected or irrelevant information deleted or blocked, to have incorrect our outdated information corrected and to object to the processing of their personal information.

Linde has the right, subject to applicable law, to restrict the exercise of these rights on a case-by-case basis in order to ensure the protection of the rights and freedoms of others involved in the scheme, in particular the reporting person.

Personal information received via the Integrity Line is typically kept as long as it is needed to conduct an investigation and to take mitigating action. All personal information received through the Integrity Line is typically deleted within four (4) weeks following completion of the review and investigation process.

Personal information received via the Integrity Line might be kept for as long as ensuing litigation lasts or as long as this is required due to legal, regulatory or contractual retention obligations. It will be deleted / anonymized as soon as it is no longer needed for the above purposes or as soon as this is required by applicable law.

Please direct any questions regarding the operation of the Integrity Line as well as any requests for information, access, correction, blocking, deletion or objection to the Integrity Line Facilitator (ILF) under
integrity@linde.com.

Your request will be dealt with as soon as reasonably possible, but not later than within four (4) weeks following the receipt of the request by the ILF. To the extent local laws require replies to be made within shorter periods, the local law provisions shall prevail.

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